Q&As

Is there a requirement to notify a change in the manner in which a PDMR holds their interest in an issuer under Article 19 of the Market Abuse Regulation where there is no change in beneficial ownership, eg where the PDMR's shareholding in the issuer has changed from one nominee account to another?

read titleRead full title
Published on LexisPSL on 12/12/2017

The following Corporate Q&A provides comprehensive and up to date legal information covering:

  • Is there a requirement to notify a change in the manner in which a PDMR holds their interest in an issuer under Article 19 of the Market Abuse Regulation where there is no change in beneficial ownership, eg where the PDMR's shareholding in the issuer has changed from one nominee account to another?

Is there a requirement to notify a change in the manner in which a PDMR holds their interest in an issuer under Article 19 of the Market Abuse Regulation where there is no change in beneficial ownership, eg where the PDMR's shareholding in the issuer has changed from one nominee account to another?

The following are useful in interpreting the persons discharging managerial responsibility (PDMR) notification provisions of the Market Abuse Regulation (EU) No 596/2014 (Market Abuse Regulation):

  1. Article 19 of the Market Abuse Regulation

  2. Commission Delegated Regulation (EU) 2016/522 which covers certain detailed aspects of the Market Abuse Regulation and lays down rules with regard to (among other things) types of transactions triggering the duty to notify managers’ transactions

  3. Benchmark Regulation (EU) 2016/1011

  4. City of London Law Society and Law Society Company Law Committees’ Joint Working Parties on Market Abuse, Share Plans and Takeovers Code Company Law Committee Market Abuse Regulation Q&As (Law Society Market Abuse Regulation Q&As)

  5. ESMA Final Report: technical advice on possible delegated acts concerning the Market Abuse Regulation, 3 February 2015

  6. ESMA Q&As on the Market Abuse Regulation, 14 December 2017

Whether a notification is required by a PDMR depends on whether a ‘transaction’ has occurred as envisaged by Article 19(1) of the Market Abuse Regulation. Article 19(1) of the Market Abuse Regulation provides that PDMRs and persons closely associated with them (PCAs):

‘shall notify

Popular documents